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    Home /  Insights /  Memos and Newsletters /  Memo
    S&C Memos

    FDIC Proposes Revised Statement of Policy on Bank Mergers

    Proposal Would Update Long-Standing Statement of Policy to Reflect Subsequent Legislative Developments and to Address “Continued Growth and Consolidation” in the Banking Industry

    March 21, 2024 | min read |
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    Today, the Federal Deposit Insurance Corporation issued a request for comment on proposed revisions to its Statement of Policy on Bank Merger Transactions (“SOP”). The proposed SOP updates the current SOP and seeks to “strengthen[] and clarif[y] the FDIC’s policies related to the evaluation of bank merger applications” under the Bank Merger Act in light of the “significant changes [that] have occurred in the banking industry and financial system” in the last two decades. As a general matter, under the Proposed SOP the FDIC would have broader discretion when reviewing merger applications.

    The request solicits public comment on all aspects of the proposed SOP and requests comments on 39 enumerated sets of questions on a broad set of topics. Concurrently with the proposed SOP, the FDIC is seeking comment on proposed revisions to its supplemental section to the Interagency Bank Merger Act Application form.

    Comments on the proposed SOP and other matters raised in the request will be due 60 days after publication in the Federal Register.

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    • Financial Services
    • Financial Services Mergers & Acquisitions
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